· the reporting by self-employed persons of injuries or illness to themselves.

HSE say that no fundamental changes are proposed to the administrative arrangements for reporting incidents and that the majority of reports will continue to be made using online report forms which are submitted directly to a central database.

At the last meeting of NOSHC concern was expressed that the commitment in the Löfstedt Review to further review the RIDDOR regulations would not be used to afford a root and branch consideration of fundamental objectives in relation to the needs of all stakeholders for data about accidents, incidents and ill health, for example to facilitate decision making about enforcement, internal health and safety management by employers and future policy development, including at sector level.

It was noted that RoSPA had argued that the reporting of notifiable dangerous occurrences (DOs) needed major revision, particularly given the overriding need to learn from serious events in which people luckily had not been harmed. The list was seen as historic and largely out-of-date. Reporting was less than 18 per cent and there was no link in guidance to the employer’s duty in their own risk assessments to identify significant D.O.s which should be reported and recorded internally.

It was also noted that, perversely, following Lord Young’s review, the decision to reduce the absence threshold for injury reporting by employers from over three days (OTD) to over seven days (rendering RIDDOR data in organisations even less statistically significant) had led many third parties such as clients and award bodies to start to ask for a new KPI of total lost time injury based on time lost beyond end of day or shift. Thus, besides having to still record internal OTD accidents more record keeping was now being required by the market.

The Committee felt that a comprehensive re-think was needed which looked at all stakeholders’ needs and which also considered how to address the problem of reporting and recording work related ill health. There was a need to get this right and not to rush the exercise, particularly since two sets of changes to RIDDOR in such a short time would not make employers’ lives simpler.

On a first reading, while we support the aim of making RIDDOR clearer, we are concerned at the proposal to strip out reporting/recording of ill conditions, accidents affecting non-employees (members of the public), many of the dangerous occurrences and nearly all notifiable ill-health conditions. More discussion is needed on these issues and more attention should be paid perhaps to the data which employers need to gather and record internally to enable them to review H&S performance and refine their risk assessments.

I would be grateful for your reactions to the proposals so we can take these into account in our response.

Please note that HSE’s closing date for receipt of comments is 28th October.

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